Title: NSPS APPLICABILITY ­ LARGE APPLIANCE PARTS COATING LINE

Recipient: MAGYAR, RAY, COMPLIANCE SECTION REGION VI

Author: SEITZ, JOHN S., SSCD

Date: 04/02/90

Subparts: SS

References: 60.450, 60.450(a), 60.451(a)

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Section 60.451(a) defines the surface coating operation subject toSubpart SS as "that portion of a large appliance assembly plant engaged in the application and curing of organic surface coatings on large appliance parts or products." Therefore, the source is subject to Subpart SS, even though assembly doesnt take place.

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April 02, 1990

SUBJECT: Applicability Determination for 40 CFR 60, Subpart SS ­ Standards of Performance for Industrial Performance Coating: Large Appliances

FROM: John S. Seitz, Director Stationary Source Compliance Division (EN­341

To: Ray Magyar, Environmental Engineer Compliance Section (6T­EC)

In response to your informal memorandum of March 13, 1990, to Barbara Durso of my staff, I have reviewed the applicability of 40 CFR 60, Subpart SS with regard to a facility in Arkansas that coats large appliance parts. The facility in question has been contracted by an appliance manufacturer to coat panels for its refrigerators, because the coating line in the manufacturers assembly plant could not be redesigned to accommodate the panels. Section 60.450(a) states that the provisions of Subpart SS "shall apply to each surface coating operation in a large appliance surface coating line." The key phrase in this applicability section is the definition of a large appliance surface coating line at Section 60.451(a): "that portion of a large appliance assembly plant engaged in the application and curing or organic surface coatings on large appliance parts or products." The owner of the facility argues that because only the coating of parts, not their assembly, occurs at his facility, his coating line is not a portion of a large appliance assembly and should not be subject to Subpart SS.

A review of the background information document (EPA 450/3­80­037b) revealed the following relevant information (page 1­1, paragraph 3):

"The definition of "large appliance surface coating line" has been changed [from proposal to final] to include only coating operations within large appliance assembly plants. This alteration is specifically intended to exclude operations that coat only certain parts, such as compressors, which are sold to a variety of large appliance manufacturers (emphasis added)."

Based on this information, it is clear that the language of the rule was not intended to exclude the kind of off­site coating operation in question here. Because this coating operation does not fall into that category which the authors of the rule specifically intended to exclude, it is subject to the requirements of Subpart SS.

cc: M. Miller, SSCD

R. Shafer, SSCD

J. Fugh, OCEM

B. Durso, SSCD